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LOEVSKY v. C.I.R.

Nos. 71-1914, 71-1915.

471 F.2d 1178 (1973)

George LOEVSKY and Ruth Loevsky, Appellants in No. 71-1914, v. COMMISSIONER OF INTERNAL REVENUE. Louis LOEVSKY and Faye Loevsky, Appellants in No. 71-1915, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided January 2, 1973.

Attorney(s) appearing for the Case

Jack N. Honart, Newark, N. J., for appellant.

Stephen Schwarz, Department of Justice-Tax Division, Washington, D.C., for appellee.

Before SEITZ, Chief Judge, and HASTIE and HUNTER, Circuit Judges.

OPINION OF THE COURT

PER CURIAM:

The income tax deficiencies that are in dispute in this case resulted from the Commissioner's disallowance of deductions claimed in the amounts of a corporation's contributions to a pension trust established to implement the corporation's pension plan for its salaried employees. In the Commissioner's view the contributions were not deductible because the pension plan did not satisfy the requirement of Section 401(a)(3)(B...

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